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Mr. S. in 1990, and sustain respondent’s determination only to
that extent.
Respondent determined that petitioner had unreported escort
income of $200 in 1989 from an individual named Eric K. A check
in the amount of $200, dated June 23, 1989, was made payable to
cash, written by Eric K., and endorsed by Jane M., who provided
escort services to customers pursuant to petitioner’s
arrangements. In these circumstances, and because the check was
deposited into the Real Services’ account controlled by
petitioner, we sustain respondent’s determination.
Respondent determined that petitioner had unreported escort
income of $875 in 1989 and $875 in 1990 from Ronald K.
Respondent’s figures reflect seven escort sessions per year at
$125 per session. Mr. K. testified on cross-examination,
consistently with respondent’s determination, that he received
escort services arranged by petitioner on 12 to 15 occasions
during the 2-year period 1989 through 1990. He also testified
that he paid approximately $125 per occasion. Petitioner’s
contention that she paid $875 of this amount in 1990 to furnish
mud wrestlers at an event sponsored by Mr. K. was contradicted by
him, and we do not accept it. Accordingly, we sustain
respondent’s determination.
Respondent determined that petitioner had unreported escort
income of $6,000 in 1989 and $6,000 in 1990 from an individual
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